Lalita Kumari v. Government of Uttar Pradesh

This case arose when police refused to register an FIR despite a complaint about the kidnapping of minor Lalita Kumari. The matter was referred to a Constitution Bench to resolve conflicting judicial opinions on whether FIR registration is mandatory under Section 154 CrPC upon receipt of information about a cognizable offense. The Constitution Bench held that registration of FIR is mandatory under Section 154 CrPC if the information discloses commission of a cognizable offense, and no preliminary inquiry is permissible in such situations. The Court clarified that preliminary inquiry may be conducted only when information does not clearly disclose a cognizable offense. This judgment resolved decades of controversy about police discretion in FIR registration, establishing clear guidelines that strengthen victims' access to justice while allowing limited scope for preliminary inquiry in specific categories like matrimonial disputes and commercial offenses.